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2 Premier Proteins (2000) Ltd. White Young Green 1.0 Non-Technical Summary of IPPC Licence Application (Site Code: ) and NHA (Site Code ). Premier (2000) Proteins Ltd (IPC licence P ), located just outside Ballinasloe, Co Galway, is engaged in the rendering of animal byproducts to produce tallow oil, and meat and bone meal. These products are produced via a series of cooking, milling and separation steps. The plant occupies approximately one third of the 4.1ha site which is located in a rural area adjacent to the River Suck. The facility operates 24 hours per day and 7 days per week and most of the process plant is enclosed in industrial buildings. The factory is a modern industrial facility that employs modern processing equipment to maximise yields and to minimise waste. Where emissions are unavoidable the Company employs the best available technology (BAT), to minimise the impact of such emissions on the environment. The plant has its own utility generation and emission treatment. Premier Proteins (2000) Ltd is situated on a sloping site approximately 1 km from the centre of the town of Ballinasloe (See Figure 1), which has a population of 6158 people (Urban and Rural)[CSO 2006]. The facility itself is located in rural surroundings with the rear of the facility backing onto the old Royal Canal line which ran parallel to the River Suck which flows through Ballinasloe and meets up with the river Shannon at Shannonbridge. The sloping hillside accommodating Premier Proteins forms part of the valley along which the River Suck is flowing. The River Suck Callows is a designated (Special Protection Area) SPA For inspection purposes only. The company was initially granted an IPC licence [Reg. No 45 (P )] on 3 rd April A revised IPC licence was issued to the company on the 10 June 1999 [Reg. No. 372 (P )]. The first review was necessary in order to facilitate updating of the odour abatement requirements, new air emission point (new biofilter), replacement of existing boilers and upgrade of the process building. Material arriving at the plant for processing is crushed and conveyed to a continuous cooker heated with steam. The cooked material is separated into tallow oil and meat & bone meal (MBM). The Company operates a continuous cooking process with a capacity of 480 tonnes per day. At present the Company is operating under IPC licence P (592). A Technical Amendment was issued to the Company in August This amendment was required to facilitate the operation of the Regenerative Thermal Oxidiser (RTO) that had been installed in order to improve the odour abatement systems at the facility and to assist in the odour mitigation along with biofilters 1 and 2. This IPPC licence review application is submitted to upgrade the facility from an IPC licence to an IPPC licence at the request of the EPA. In conjunction with this upgrade to IPPC and as a result of the installation of the Regenerative Thermal Oxidiser, the Company proposes to accept additional materials namely dewatered sludge (from Municipal WWTPs), used cooking oils (UCOs), food waste (from the catering/food 1 CE04877 Oct 2007 EPA Export :00:52:48

3 Premier Proteins (2000) Ltd. White Young Green industry), and waste waters (grease trap liquid waste from grease traps and interceptors, sewerage washdown etc), details of which are outlined below. Premier Proteins (2000) Ltd proposes to accept used cooking oils (UCO) for purification and blending into tallow produced on site. The UCOs either will be transported in road tankers or closed 200L to 1000L containers. They will initially be received into the existing processing day tank. The oils pass through centrifugal decanters and a separator to remove impurities. Oil will be sterilised and purified in accordance with EC Regulation 1774/2002. They will then be blended with normal production tallow before going to storage. Ultimate recovery will be through use as fuel in approved boilers. No additional storage or process modifications will be required to accept UCOs for processing. input streams to be processed at the plant are presently not defined it is planned that they will make up the shortfall in the processing capacity of the plant as stipulated in the existing IPC Licence (P ). Therefore, there will be no increase in the overall quantities of materials accepted and processed at the plant. The waste waters will be transported to site in sealed road tankers. On arrival the tankers will be weighed and directed to an offloading point. The wastewaters will be received into the proposed new holding tanks and will undergo analysis prior to discharging to the Wastewater Treatment Plant (WWTP). Eight new holding tanks are proposed adjacent to the Raw Material Intake area (See Figures 4 and 5). Loads will be tested for toxicity, Chemical Oxygen Demand and TKN. The liquid will be piped into a sump and pumped to the pre- In addition the Company proposes to accept food waste and dewatered sludge which will be transported to the site in closed containers. On arrival at the site the dewatered sludge and catering waste will be handled and processed along with the existing raw materials in screen. Once pre-screened, the liquid will be passed through the dissolved air flotation (DAF) unit to remove fats and oils. Any solid material recovered at the screen will be diverted to the cooker in the process building for processing as normal. The pre-screen and DAF unit are accordance with EC Regulation 1774/2002. situated within an enclosed building incorporating air extraction which is sent to Dewatered sludge will be analysed prior to biofilter 2. The liquids will then be treated in the acceptance at the facility to ensure compatibility waste water treatment plant (WWTP) in with the plant processes. The dried material will be incorporated into meat and bone meal activated sludge tanks along with normal effluent streams. produced on site and will be disposed of by incineration/co-incineration at approved At present Premier Proteins conducts weekly facilities. The acceptance of the UCOs, food analysis of the influent on transfer to the Waste waste and sludge will not require any water treatment plant. The influent is collected modification to the existing plant or processes. automatically in a sterile bottle every hour and sent for analysis over a 24hr period. There has been a reduction in the amount of raw materials processed at the plant over the past year. While the exact quantities of the new It is proposed to screen the proposed wastes on arrival to the facility prior to acceptance to For inspection purposes only. 2 CE04877 Oct 2007 EPA Export :00:52:48

4 Premier Proteins (2000) Ltd. White Young Green the proposed new holding tanks. The new materials will be pumped to the WWTP from the holding tanks and will merge with the site generated effluents. The mixed influents can be monitored from the existing influent monitoring point on a daily, weekly or monthly basis prior to acceptance to the WWTP. The monitoring locations and grid references for each of these points are shown on Figure 3. The grease trap waste to be accepted will be sourced from restaurants and the food services industry. The waste typically contains two to five percent grease with a high organic content. However, the concentration ratio of oil to water of the Grease trap waste is dependant on the source of the material. Grease trap wastes with a higher oil-water concentration will be eligible for oil/grease recovery and the material can be accepted directly to the press area to be treated operating within the scheduled emissions limit values of that licence, however these limits are not in line with the BATNEEC Guidance limits of 15mg/l for Total Nitrogen concentrations. Under the existing licence the ELV for Total Nitrogen is 40mg/l and the facility currently operates within this limit. Total nitrogen levels in 2006 were above the BATNEEC guidance of 15mg/l on six of the 12 monitoring events in However it should be noted that the average emission for total Nitrogen for the period monitored is 15.4mg/l which is marginally above the ELV. The minimisation of emissions from the facility processes in conjunction with the conservation of energy and resources is a priority for Premier Proteins as demonstrated by the recent facility upgrade and installation of the Thermal Regenerative oxidiser. (RTO). The installation and purified as oil. It can then be blended with of this abatement system has diverted 30,000 the Tallow oil as per the UCOs. litres of wastewater from the WWTP. All sludge generated at the WWTP is returned During the preliminary stages of the operation of to the intake area for processing, sterilisation the RTO, the facility experienced initial technical and disposal by incineration at approved difficulties which meant that the RTO was not in facilities. Acceptance of these wastewaters will operation 100% of the time. This is evident in not necessitate any process modification. It is the analytical results from the WWTP effluent. not possible at this time for the Company to In July, August and October the figures for total define the exact quantities of wastewaters to be nitrogen were elevated above the Current accepted at the facility as the market is only just BATNEEC limit values (27 mg/l, 18mg/l and starting to develop. However, the total volumes 27mg/l respectively). The oxidizer was in treated in the WWTP will not exceed the operation in November and December 2006 existing capacity of the WWTP as stipulated in and total nitrogen levels dropped to below the the current IPC Licence (P ). Therefore, BATNEEC limit of 15mg/l. In January the there will not be any increase in emissions from Oxidiser had to be shut down due to technical the facility and no significant impact on the local difficulties and once again the Total Nitrogen aquatic environment. levels were elevated above the BATNEEC ELV s. Under the existing IPC Licence (P ) emission limit values (ELV s) have been set for An assessment of the impact of the WWTP on emissions to water. At present the facility is the receiving environment was conducted in For inspection purposes only. 3 CE04877 Oct 2007 EPA Export :00:52:48

5 Premier Proteins (2000) Ltd. White Young Green April The assessment concluded that the overall river quality (biological and chemical) is mostly satisfactory however the biological water quality data does indicate deterioration in ecological river water quality since the previous monitoring event in Chemical dtata for the river upstream and downstream of the facility indicated moderate surface water quality with all parameters below their respective EQS values with the exception of Ammonia levels at both locations monitored with slight elevations above the EQS value. Assimilative capacity calculations were conducted for a number of parameters. Assimilative capacity calculations are based on the hydrometric data from the OPW Hydrometric Station at Bellagill situated approximately 5km northwest and upstream of the Premier Proteins outfall point at Pollboy. The results indicated minor and negligible increases in concentrations of all parameters to the receiving waters downstream of the discharge point at Pollboy from the Premier Proteins Waste water treatment plant compared to upstream concentrations. This increase in concentration would not significantly influence the quality of the receiving water. Therefore the River Suck has abundant capacity for assimilation of the treated waste water as discharged from Premier Proteins (2000) Ltd. An assessment of the impacts of emissions from the WWTP on the atmosphere was also conducted. All on-site plant items have previously been covered. These include the holding tank, the screening area, the flotation tank, the balance tank, aeration tanks and treated effluent buffer tank. All foul air from these tanks is extracted and treated though biofilter No. 2 only. Therefore, the only source of odour emission from the WWTP is from the biofilter. An odour monitoring survey carried out in 2001 on biofilter No. 2 recorded an odour concentration of 67ou E /m 3. This indicates an efficiently operating biofilter that is successfully treating foul air from the WWTP. Typical odour levels of up to 500ou E /m3 are emitted from efficiently operating biofilters. To ensure that the WWTP does not adversely impact on the receiving environment, the following mitigation measures have been implemented: Premier Proteins will comply with all conditions stipulated in S. I. No. 787 of For inspection purposes only for the prevention of causing nuisance through odour generation from WWTP Compliance Conditions in the company s Waste Licence in all issues relating to odour All new holding tanks will be covered. Foul air will be extracted and treated in biofilter No. 2 All existing tanks and odour producing activities at the WWTP are covered A daily visual inspection of the biofilter A regular and documented maintenance programme for the biofilter Preparation and implementation of an odour management plan for the plant Maintaining the effluent aerated other than in processes that are specifically anaerobic Avoiding anaerobic conditions and minimising septicity Implementation of an odour complaints register to be integrated into the odour management plan 4 CE04877 Oct 2007 EPA Export :00:52:48

6 Premier Proteins (2000) Ltd. White Young Green Training of staff having duties relating to the management, operation, maintenance or repair of the WWTP and the biofilter Adherence to the BREF Notes for the Slaughterhouses and Animal By- Products Industries and the EPA BAT Guidance Notes on Best Available Techniques for the Slaughtering Sector as well as the EPA BATNEEC guidance notes for the Rendering of Animal By- Products in relation to odour abatement Regenerative Thermal Oxidiser EPA compliance for odour reduction (Aug 2006) The following energy sources are used to operate the facility. Tallow oil is used exclusively at the two 15,000kg/hr steam boilers. Both boilers are currently serviced at least twice per annum to ensure efficient combustion. Burners are set up to ensure optimum combustion efficiencies at all times. Since the issue of the previous licence (P ) the facility has been altered to facilitate compliance with the EPA and also to facilitate changes to the Licence (on approval from the EPA). These changes and their reasons include the following: Installation of a Separator Solids Approximately 3.85 million litres/year of tallow removal from tallow oil is used as a fuel in the steam boilers for the The belt press was changed to a decanter in WWTP Permits reduction of water usage Installed a tank for receiving liquid Blood for processing EPA compliance Installed Tallow steriliser EPA compliance Installed water steriliser EPA compliance Additional Tallow storage tanks To improve tallow stock management New raw material Intake area with Air lock system - EPA Compliance Fat scrubber To improve performance of Biofilter 1 Interceptor To provide further protection to Surface water For inspection purposes only. The use of fuel oil is now totally discontinued, with the fuel oil being replaced by the more sustainable tallow oil. This practice is beneficial to the environment in relation to sulphur dioxide (SO 2 ) emissions, as the sulphur content of tallow is generally insignificant whereas the sulphur content of medium or light fuel oil is now controlled by EEC Directive at 1% or less. production of process steam and now accounts for 100% of these energy requirements. There will be no additional sources of emissions arising from the additional processes outlined in this application. An energy audit was conducted in late The findings of which are discussed in Attachment No G. In 2006 the company were granted permission from the EPA to install a regenerative thermal oxidiser at the facility to filter and purify the odorous gases that have been generated throughout the process. See drawing No AK7001 in Attachment A for structural details. There will be no extra effluent emissions to waters as all vapours from the cooking and sterilisation is treated by thermal oxidation. Effluent volumes emitted from the WWTP will 5 CE04877 Oct 2007 EPA Export :00:52:48

7 Premier Proteins (2000) Ltd. White Young Green not exceed the ELV of 290m 3 /day as the thermal oxidiser has removed approximately 60% of effluent volume. Monitoring of emissions into the surrounding environment is as per the conditions of P It is expected that there will not be any significant effects on the environment as the loading on the plant will be kept within the design parameters of 1400kg BOD/day and 2323kg COD/day. As mentioned above the use of fuel oil is now totally discontinued and replaced by the more sustainable tallow oil. The environmental benefit of using tallow oil as a replacement for fuel oil includes the discontinued use of a natural resource and a reduction in the emission of sulphur dioxide to the atmosphere by approximately 72 tonnes per annum, based on present tallow consumption. Premier Proteins operates the facility to stringent control measures as stipulated in the existing IPPC Licence. In addition, the company have safety management plan and hazard risk assessment in operation as well as numerous safety operations manuals. For inspection purposes only. 6 CE04877 Oct 2007 EPA Export :00:52:48

8 Premier Proteins (2000) Ltd. White Young Green 2.0 With regard to proposals to blend used cooking oils (EWC ) with tallow oil, please set out a rationale as to why it should be considered a fuel and not a waste. This should include requirements to be met and evidence of Department of Agriculture and Food approval where required. Provide details of any obligations to register under the REACH Regulations (For the Regulation, Evaluation and Authorisation of Chemicals) 2.1 Used Cooking Oil Classification Under the Waste Management Act 1996 and its amendment of 2001 waste is defined as any substance or object...which the holder discards or intends or is required to discard, and anything which is discarded or otherwise dealt with as if it were waste shall be presumed to be waste until the contrary is proved. Under article 2 (2b) of the EU Directive 2003/30/EC on the promotion of the use of biofuels or other renewable fuels for transport biodiesel : is defined as a methyl-ester produced from vegetable or animal oil, of diesel quality; Premier Proteins have applied for a review of their IPC licence to update the existing licence in line with IPPC and also to extend their class of activity to include 11.1 The recovery or disposal of waste in a facility, within the meaning of the Act of 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be required. Premier Proteins have openly proposed to accept the waste materials outlined in the review application and associated additional information responses, namely dewatered sludge, grease trap waste, catering food wastes and used cooking oils. The typical composition of used cooking oil has been provided in the previous response to further information. For inspection purposes only. The Department of Agriculture approval for the use of Tallow in the Premier Proteins boilers is attached below. Under Licence C01/4 Premier Proteins are licenced to dispose by co-incineration, tallow derived from specified risk material. In recent years with the advent of the need to investigate alternative fuel sources to fossil fuels, used cooking oils have been trialled as a substitute to conventional fuels with successful results. There are numerous research studies and trials reported in Ireland and abroad. In 1998, Teagasc published Bio-Diesel Production from camelina oil, waste cooking oil and tallow whose aim was to examine the potential of alternative vegetable oils, oil wastes or animal fats as bio-diesel feedstocks. The work concluded that used cooking oil is the most promising raw material for use as an alternative fuel. It is 7 CE04877 Oct 2007 EPA Export :00:52:48

9 Premier Proteins (2000) Ltd. White Young Green therefore a valuable commodity to the bio-fuels and rendering industry. Used Cooking oils have also been promoted as non-toxic, biodegradable and carbon neutral. Cooking oil is produced from vegetable and nut sources, containing high fat allowances and remains liquid at room temperature. The term used cooking oil refers to cooking oil that is no longer viable in food production (SEPA 2007). Catering wastes are referred to in Articles 1, 4, 5 and 6 of Regulation 1774/2002, the Animal Byproducts Regulation. In Article 1, the types of acceptable catering waste are outlined namely: it is categorised as Category 1 material if it is catering waste from means of transport operating internationally (e.g. ships going from Ireland to England). Under the Directive in Annex 1 point 15 catering waste; Means all waste food originating in restaurants, catering facilities and kitchens, including central kitchens and household kitchens ; However Annex I of Regulation 1774/2002 was amended in Commission Regulation (EC) No 808/2003 of 12 May 2003, as follows: Catering waste means all waste food including used cooking oil originating in restaurants, catering facilities and kitchens, including central kitchens and household kitchen Premier Proteins propose to collect used cooking oils from persons who may or may not regard them as a waste as they may have to discard them. However, once received by Premier Proteins the oil ceases to be waste and is treated as an animal by-product as per the Animal By-Products Regulations and its amendments as it may contain quantities of meat from the production/preparation of food. For inspection purposes only. In Article 6 of the Animal By-Products Directive, catering waste other than that referred to in Article 4(1) (e) is defined as Category 3 material. This corresponds with the used cooking oils that Premier Proteins propose to accept at the facility. Under the legislation these may be dealt with and processed as provided for in Regulation 1774/2002. Used cooking oils will be processed in accordance with the Animal By-Product Regulations and can then also be used as a fuel replacing natural resources. 2.2 REACH Regulations The REACH (Registration, Evaluation and Authorisation of Chemicals) regulation came into force on 1 June 2007, and it requires that all (approximately 30,000) chemicals produced & marketed in the EU in excess of 1 tonne per year quantity will have to be registered with a complete technical dossier. Registrations of substances used in excess of 10 tonnes per year will require a chemical safety report with the technical dossier and must include a chemical safety assessment. The stages involved in REACH are as follows; 8 CE04877 Oct 2007 EPA Export :00:52:48

10 Premier Proteins (2000) Ltd. White Young Green Registration of substances produced or imported in volumes greater than 1 tonne per year. Evaluation of testing proposals and data provided to Agency and Member States under the registration procedure and evaluation of substances with potential risks, which may lead to the authorisation and restriction procedures. Authorisation of specific uses of substances of high concern. Chemicals includes chemical substances, chemical preparations, substances in articles e.g. ink in an ink jet Tallow oil is exempt from requirements to register under Annex IV of the Regulations. In addition, many vegetable oils and their physically modified derivatives are included in Annex IV of the Regulations thereby exempting them from the requirements of the legislation. Glycerides and fatty acids, carboxylic acid and methyl esters are all included in Annex IV and are therefore exempt from the Regulations. Used cooking oil itself is not listed however as each of the vegetable oils and their Derivatives are listed it is clear that used cooking oils are also exempt. Premier Proteins (2000) Ltd. is therefore not obliged to register under the REACH Regulations (for the Registration, Evaluation and Authorisation of Chemicals). For inspection purposes only. 9 CE04877 Oct 2007 EPA Export :00:52:48

11 Premier Proteins (2000) Ltd. White Young Green 3.0 Provide a copy of written approval and associated conditions from the Department of Agriculture for use of tallow oil in the RTO and boiler 3.1 Department of Agriculture and Food approval of tallow oil use in the RTO and boilers See below For inspection purposes only. 10 CE04877 Oct 2007 EPA Export :00:52:48

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14 Premier Proteins (2000) Ltd. White Young Green 4.0 With regard to proposals to render municipal dewatered sludge, identify any associated environmental risk including impacts on emissions to air and water and any implications for tallow oil and meat and bone meal (MBM). 4.1 Response Currently the rendering process involves cooking the animal by-products and then separating the oil (tallow) and meat and bone meal (MBM). The cooking vapours are condensed in air cooled condensers and the resulting remaining condensate is treated in the WWTP. Both the MBM and tallow are sterilised prior to dispatch. The MBM is disposed of by thermal destruction and energy recovery by approved power generating facilities in various EU countries and cement factories in the EU and Ireland. The tallow produced is used as a boiler fuel onsite and at other EPA approved locations. Premier Proteins propose that the sludge accepted on site will be processed along with the normal animal by-products and the SRM. The processed sludge will be sterilised (133 o C at 3 Bar A for 20 minutes) along with the MBM. The end product (a mix of meat and bone meal and dried sludge) would then be sent for thermal destruction and energy recovery, as is currently the case with the MBM. At present as per condition 8.4 of P (excerpt below) all primary sludge [Dissolved Air Flotation (DAF) sludge] and secondary biological sludge arising from the waste water treatment plant is returned to the intake building. 8.4 All preliminary and primary sludge, in particular dissolved air flotation (DAF) sludge as well as secondary biological sludge arising shall be returned to the intake building for processing. There shall be no landspreading of sludge derived from the on-site waste water treatment processes Currently dewatered sludge is returned to the intake building at a rate of 1 tonne per hour for processing. The facility is processing a total of 16 tonnes per hour. Typically this volume of dewatered sludge would constitute approximately 6.25% of the hourly material intake for processing. Therefore at present, emissions to air from the 2 boilers and the regenerative thermal oxidiser incorporate the processed dewatered sludge from the onsite WWTP. Table E.1 can be found in section 5 and details the emissions to air from the 2 boilers. For inspection purposes only. As described in the response to further information request dated 2 nd May 2007 it is proposed to accept dewatered sludge to the facility into the raw material intake area and pass it through the cooker as per the dewatered sludge from the WWTP and animal by-products arriving directly to the facility. Any residual water vapours shall be evaporated in the Thermal Oxidiser thereby minimizing the amount of wastewater generated. The Company proposes to accept waste sludge which will be transported to the site in closed containers. On arrival at the site the sludge will be tipped and processed in accordance with EC Regulation 1774/2002 and its amendments. The dried material will be incorporated into MBM produced on site and will be disposed of by incineration/co-incineration at approved facilities. The facility will not exceed the processing capacity stipulated in their IPPC Licence and the proportion of dewatered sludge 11 CE04877 Oct 2007 EPA Export :00:52:48

15 Premier Proteins (2000) Ltd. White Young Green in the hourly processing rate will not exceed 10% of the total hourly processing rate because it has been found that when dewatered sludge is processed with the SRM and animal by-products the calorific value of the end-product is slightly reduced. The WWTP is monitored for Mixed Liquor Suspended Solids (MLSS) concentration, half hour sludge settlement test and sludge volume index on a daily basis. The F/M ratio and a microscopic examination of the sludge are conducted weekly (in accordance with P ). As mentioned previously the composition of the proposed dewatered sludge will vary greatly depending on its source. Therefore Premier Proteins will not accept sludge to the facility without a recent and complete analysis Emissions to water As stated in the original review application the operation of the Regenerative Thermal Oxidiser (RTO) has led to a significant reduction in the volume of wastewater treated at the wastewater treatment plant (a reduction of 30,000 m 3 /annum) and therefore the plant has ample capacity to treat additional quantities of wastewater. Emissions to water from the WWTP have been dealt with in previous responses to further information. Any remaining water generated in the facility processes is evaporated in the boilers and the RTO. As the facility operates within the emission limits outlined in the EPA IPPC licence, with the use of the existing abatement systems there will be no environmental impacts to water from the acceptance of dewatered sludge to the rendering process. In addition the facility will not process dewatered sludge at more than a 10% proportion of the total hourly tonnage Emissions to Air For inspection purposes only. Emissions to air from the facility are dealt with using the abatement systems listed below: Biofilter 1 Biofilter 2 Acid Scrubber Fat Scrubber Boilers Regenerative Thermal oxidiser (RTO) Details of the above mentioned abatement systems were submitted in the original review application and have been included here again in Attachment 3.1. The proposal to accept additional dewatered sludge to the facility along with the existing raw materials will not create any additional impact on the environment through emissions to air. In addition there will be no implications for tallow oil from the addition of dewatered sludges 12 CE04877 Oct 2007 EPA Export :00:52:48

16 Premier Proteins (2000) Ltd. White Young Green 5.0 Provide typical composition data for each of the two wastewater streams and clarify the options for processing EWC depending on its composition Please see below the revised compositional table of the proposed wastewaters to be accepted at the wastewater treatment plant via the material receptions tanks. Table 4.1: Description, source and composition of EWC codes Typical Composition Waste material EWC Code Source BOD COD OILS FATS & % DRY GREASES MATTER Municipal Dewatered sludge Municipal WWTP s 20 <75mg/l 18-22% Used Cooking oil Catering/Food Industry n/a n/a 100% 1% Food Waste Catering/Food Industry For inspection purposes only. Waste water (Grease trap) Food services industry such as Restaurants/ Hotels etc. Waste waters from Grease traps % - It should be noted that these figures are indicative of typical compositions only and cannot be taken as exact reflections of potential new material intake. As mentioned previously, Premier Proteins has not completed the market research for the proposed new materials. When proposed materials have been sourced they will be analysed and the results will be sent to the EPA for approval prior to acceptance to the facility. 13 CE04877 Oct 2007 EPA Export :00:52:48

17 Premier Proteins (2000) Ltd. White Young Green 5.1 Options for processing depending on its composition The options for processing have been discussed at length in the previous response to additional information and in the original review application. The wastewaters (grease trap wastes) will be transferred into the proposed new wastewater holding tanks as described in the previous responses. Wastewaters will undergo analysis prior to discharging to the WWTP. Loads will be screened for toxicity, Chemical Oxygen Demand and Total Kjeldahl Nitrogen (TKN). Frequency of testing will be increased for new sources and any other source which for any reason may be suspect. Should a sample show the liquid to be unsuitable for biological treatment then it will be transferred to the main processing building and processed in the cooker (i.e. evaporated) and the vapours will be treated in the Thermal Oxidiser. After testing, the wastewater will be discharged to the WWTP where it will be screened to remove solids. The liquid will be offloaded into a sump and pumped to the pre-screen. It will then pass through the Dissolved Air Flotation (DAF) unit and any further solids recovered will be pumped back to the cooker for processing. The dissolved air flotation (DAF) unit separates and removes suspended and colloidal solids, as well as fats, oil, and grease from the liquid proportion. The pre-screen and DAF unit are situated within an enclosed building the air from which is extracted to the existing Bio-filter 2. The grease trap waste to be accepted will be sourced from restaurants and the food services industry. The waste typically contains two to five percent grease with a high organic content. However, the concentration ratio of oil to water of the grease trap waste is dependant on the source of the material. Grease trap wastes with a higher oil-water concentration will be eligible for oil/grease recovery and the material can be accepted directly to the press area to be treated and purified as oil. It can then be blended with the Tallow oil as per the Used Cooking oils (UCOs). For inspection purposes only. The only proposed material that will be directly entering the WWTP will be the grease trap wastes with an oil, fats and greases content of <3%. The concentration of the grease trap waste will be determined during the initial screening prior to acceptance to the facility. Based on the design characteristics of the WWTP, the facility will have the ability to accept the additional material into the process in conjunction with the existing processes. 14 CE04877 Oct 2007 EPA Export :00:52:48

18 Premier Proteins (2000) Ltd. White Young Green 6.0 Complete Table E.1 (i) Boiler Emissions to Atmosphere of the IPPC Application Form for all significant boiler emissions Emission Point: Emission Point Ref. N o : Location: Grid Ref. (12 digit, 6E,6N): Table E.1 (i) BOILER Emissions to Atmosphere CS1 and CS2 Rear of boiler house E N (1 Page for each emission point) Vent Details Diameter: 1.2 m Height above Ground(m): 30m Date of commencement of emission: Feb 1998 Characteristics of Emission: Boiler rating Steam Output: Thermal Input: 15000kg/hr MW Boiler fuel Tallow / LFO Type: Maximum rate at which fuel is burned % sulphur content: 1002kg/hr <1% sulphur NOx 400mg/Nm 3 0 o C. 3% O 2 (Liquid or Gas), 6% O 2 (Solid Fuel) Maximum volume* of emission 15000m 3 /hr 0 o C, 3 % O 2 (liquid or gas), 6 % O 2 (solid fuel) Temperature 230 o C (Max) 180 o C(min) o C(avg) * Volume flow limits for emissions to atmosphere shall be based on Normal conditions of temperature and pressure, (i.e. 0 o C, 101.3kPa), dry gas; 3% oxygen for liquid and gas fuels; 6% oxygen for solid fuels. (i) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up/shutdown to be included): Periods of Emission (avg) For inspection purposes only. 60min/hr for 24 hr and 365 days per year. 340 day per year more typical 15 CE04877 Oct 2007

19 ATTACHMENT 3.1 PREMIER PROTEINS (2000) LTD. ON REGENERATIVE THERMAL OXIDISER AND OTHER ABATEMENT SYSTEMS AT THE FACILITY For inspection purposes only.